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G.R. No.

204481-82, Oct 14, 2015

Ambagan v. People

J, Velasco.:

FACTS: A shooting incident between the party of Santos and the party of Ambagan occurred. Inholding
petitioner Ambagan criminally liable for double homicide as principal by inducement, the Sandiganbayan
gave credence to Ronnel Bawalan’s testimony that it was petitioner Ambagan’swords (“Sige, yan pala
ang gusto mo. Mga kasama banatan na ninyo yan.”) which impelled his men to aim and shoot at the

ISSUE: Whether a testimony not entirely credible can establish beyond reasonable doubt the
petitioner’s guilt.

HELD: NO. A testimony that an accused made a statement which allegedly initiated the shootout, such
testimony not being entirely credible, cannot sustain the conviction of said accused as principal by

The Sandiganbayan would have been correct if the statement was indeed made by the petitioner
immediately before the shooting incident. However, there are substantial inconsistencies in the
testimonies of star prosecution witnesses Patam and Ronnel Bawalan, which refer not only to minor
details but even to facts constituting important aspects of the case, seriously eroding the weight of the
evidence of the prosecution, and casting reasonable doubt on the culpability of petitioner.
GR No. 215341, Nov 28, 2016



FACTS: AAA's mother sent her on an errand in order to buy Milo at a store. On her way back home, she
met Manson near a vacant lot. He asked AAA to help him look for eggs in the grassy place. Once there,
Manson suddenly strangled her from the back, rendering her unconscious. She felt pain in her genitals
and in her neck. Later, she discovered that her genitals were bleeding. When she reached her house at
around 6:00 p.m., her mother, BBB, saw that AAA's face and neck were bluish. When asked what
happened to her, AAA answered, "Pangga (Manson's nickname) strangled me." BBB likewise noticed
that AAA's pants were drenched. When she checked and pulled her pants down, she was shocked to see
that her daughter's genitals were bleeding profusely.

ISSUE: Whether the prosecution has established beyond reasonable doubt Manson’s guilt.

HELD: Yes. Prosecution has proved the following circumstances: that AAA's mother sent her on an
errand on the afternoon of December 10, 2006; that on her way back home, AAA met Manson near a
vacant lot and the latter approached her to allegedly help him look for eggs in the grassy place; that AAA
was alone with Manson when they went to the grassy area of the lot; that once there, Manson suddenly
strangled her, leaving her unconscious; that when she woke up, she felt pain in her genitals and in her
neck, and saw that her genitals were already bleeding; that the physician who examined AAA found
multiple injuries on her neck, face, and eyes which are consistent with the claim of strangulation; and
that the medical report clearly shows that AAA suffered a fourth (4th)-degree laceration in her ano-
genital area which could have been caused by a blunt object, usually the male sexual organ.
G.R. No. 190178, February 12, 2014





FACTS: AAA claims that the accused, a former suitor, abducted her and brought her to his house. There,
he raped her many times for more than a week. The accused invoked the sweetheart theory and
presented witnesses who testified that they saw AAA and the accused live together and that when AAA
was missing, instead of going to the police, the family of AAA instead talked with the accused regarding
their marriage plans.

ISSUE: Whether the accused is guilty beyond reasonable doubt of the crime of rape.

HELD: No. A conviction in a criminal case must be supported by proof beyond reasonable doubt, which
means a moral certainty that the accused is guilty; the burden of proof rests upon the prosecution. In
the case at bar, the prosecution has failed to discharge its burden of establishing with moral certainty
the truthfulness of the charge that appellant had carnal knowledge of AAA against her will using threats,
force or intimidation.
GR 185209, June 28, 2010

People of the Philippines v. Baron

Del Castillo:

FACTS:: Baron and two others were charged with the special complex crime of robbery with homicide. It’s
alleged that they asked the victim to have them ferried to another hacienda with his tricycle and the victim
was found dead the following day and the tricycle was missing. However, there is only circumstantial
evidence to prove their guilt.

ISSUE: WON the accused may be convicted of the crime charged with only circumstancial evidence?

HELD: Yes. Circumstantial evidence is sufficient to sustain a conviction if:(1) there is more than one
circumstance; (2) the facts from which the inferences are derived have been established; (3) the combination
of all the circumstances is such as to warrant a finding of guilt beyond reasonable doubt. All the elements are
present in this case.